Privacy Policy

Updated 2025-02-19

1. Contact information

Our contact person for data protection

Steerpath Oy

Alberga Business Park

Bertel Jungin aukio 3

02600 Espoo

+358 9 23161155

support@steerpath.com

2. Purpose and legal basis for processing personal data

We process your personal data in order to provide the Steerpath Smart Office Service (“Service”). For further information on the Service, please see the accompanying Terms Of Service.

The data subject is the user or the Service. The basis of processing is the performance of a contract. 

The purposes of the processing are the following:

  • Identification

  • Communications

  • Provision of the Service

  • Monitoring and improving service

3. Regular sources of information

We receive information about you when you provide it through using Steerpath Smart Office or through the information that the corporate registration and login provides. We do not  buy data from 3rd party vendors nor do we provide your data to anyone except your organisation for the purposes stated in the Terms Of Service and in this Privacy policy. The data we collect are for example your name, email and any other data you have provided us through the Service, or that the phone provides the Service, as you use it. 

The application and operating system may request certain permissions to access information, such as the “GPS” location, and by granting the application permission, the application may relay this information to servers to carry out the purposes outlined in section 2. 

The Service may use occupancy sensors for monitoring room or seat occupancy. The sensor does not identify the user, but the occupancy data may be combined with booking data. If the user is part of a booking, the occupancy sensor data may be combined with the booking information. If there is no booking the data will be handled anonymously.

Bluetooth beacon hardware does not collect any data.

4. Duration of processing

We will receive your personal data when you start using the Service and we will retain your information to carry out the functions as outlined in section 2, unless you request us to delete it (see section 5).

5. Your rights

You have the following rights: 

Access, rectification and portability

You have the right to access and correct your personal data retained in our register. You can view, correct, transmit and delete your customer data by sending us a request to support@steerpath.com. 

Deletion of personal data / “Right to be forgotten”

If you feel that the processing of some of your personal data is not necessary for our processing purposes, you have the right to ask us to delete that data. If you wish to delete information, we will process your request as soon as possible, after which we will either delete your information or provide you with a valid reason why the information cannot be deleted.

Objection to processing

You have the right to object to the processing of your personal data in full or in part at any time if you feel that we have processed your personal data unlawfully or that we do not have the lawful basis to process your personal data. We will process your request as soon as possible.

Complaint

You have the right to file a complaint with the Data Protection Ombudsman if you feel that we are in breach of applicable data protection laws when processing your personal data.

6. Disclosure of Information

This is a complete list of parties Steerpath may use as subprocessors can be found in the Appendix “Steerpath Smart Office subprocessors”.

These service providers do not have the right to view your information unless necessary to ensure the functionality of the service.

We may use subcontractors to develop our services. These subcontractors may, in order to perform their job functions, access our databases containing your data. All our subcontractors and their personnel are bound by strict professional secrecy and confidentiality. 

We do not sell your personal data to others.

7. Personal data stored in Steerpath backend

Steerpath Smart Office supports SSO sign on from Microsoft and Google. Steerpath does not duplicate a person's calendar or booking information or data associated with their Microsoft or Google accounts in the Steerpath backend. Beyond name and email address, Steerpath primarily stores only data that is not available or otherwise exists in Microsoft or Google platforms.

Personal data stored in Steerpath system:

  • Name

  • Email address

  • Profile picture if set by user

  • App settings (language selection etc. from profile page)

  • Weekly planner input (at office, remote, other)

  • Other information the user inputs about himself

  • Team members

If the user shares their location:

  • Only the last location is stored on the Steerpath server, and it is only stored in memory and it disappears after 15 minutes.

  • For clarity: Steerpath does not collect the history of shared locations and the current location is only stored temporarily and only stored in memory.

If Steerpath Indoor Positioning is used in the organisation, the following diagnostic information is collected unless the organization explicitly opts out:

  • Bluetooth beacons the user’s device has seen and the signal strengths. 

  • Calculated position where the beacons were seen.

  • Device id

Examples of personal data NOT stored in Steerpath backend

  • Calendar entries

8. Data transfers outside the EU

Steerpath does not directly process or store data outside the EU + EEA area. In normal cases, data from the service's user is not transferred outside the EU or the European Economic Area.

Although the data centers selected by Steerpath are all located in Europe, it is still possible for the service providers used to transfer data outside the EU/EEA under certain circumstances. In these cases, the personal data is transferred according to the EU's standard contractual clauses for handling personal data. 

For more information about this can be found in the document “Steerpath Smart Office Subprocessors”.

Appendix: Steerpath Smart Office Subprocessors

Moved to separate document, see: Steerpath Smart Office Subprocessors